A reference, not an opinion column
The recurring practical questions, answered directly, with the source named so you can check rather than trust. Where the honest answer is that it depends, this says what it depends on.
There is a particular kind of question that circulates constantly among training providers and never gets a clean answer. Can we do this. How long must we keep that. Does this change need approval. What counts as evidence for this requirement. The questions are ordinary, they have answers, and the answers are scattered across standards, regulator guidance, fact sheets, funding contracts and state requirements, several of which contradict each other in appearance if not in substance.
What fills the gap is a folklore that circulates in closed groups, at conferences and between consultants. Some of it is accurate. Some of it was accurate three revisions ago. Some of it is one auditor's view in one audit, generalised into a rule. It is confidently stated in all three cases, and a provider cannot distinguish between them from the outside.
This publication exists to do something narrow: to answer the recurring questions in plain terms, and to name where the answer comes from so that a reader can verify it rather than take it. That second part is the point. An answer without a source is another piece of folklore, however well informed, and the fleet standard here is that a reader should be able to check.
It also means being explicit about the shape of an answer. A great many of these questions have three parts: what the national standards require, what the regulator's guidance says about how that is assessed, and what an individual funding contract or state requirement adds. Providers frequently receive an answer to one of those and apply it as though it settled all three.
The other thing worth stating plainly is what this cannot do. It is not advice about a specific provider's situation, it cannot account for conditions imposed on a particular registration, and it is not current the moment a standard changes. Everything here should be read as a starting point that tells you what to go and read.
The editorial bias is toward saying that something is uncertain where it is. A surprising proportion of the confidently answered questions in this sector are genuinely unsettled, either because the standards are silent or because practice varies between assessors, and pretending otherwise is how folklore is manufactured.
Where a question turns out to be a decision rather than a rule, this will say so. A great many things providers ask permission for are matters of judgement that they are entitled to decide, and knowing which category a question falls into is frequently more useful than the answer.
A final note on how to use anything published here, including by this title. The correct response to a confident answer about a compliance question, from any source, is to ask where it comes from and then to read that. Where a source cannot name the instrument, the answer is somebody's recollection. This publication cites so that it can be checked, and a reader who checks and finds it wrong has done exactly what the citation is there for.